We bought a pool of 100 loans in 2005 and have limited HMDA data. Reviewing HMDA GIR I see some data that does not need to be reported on purchased loans. By the way, none of these are in our MSA.

Would you agree that the following data does not need to be reported on the purchased loans?
1) PreApproval request - code as 3
2) Ethnicity, Race, Sex, Income - all entered as not applicable
3) Pricing related data - none provided leave blank

Thanks for your expert opinion.

1) Correct
2) Correct; you may collect and report this information, but you are not required to
3) Report as "NA"

In addition to those fields, "Date Application Received" is reported as "NA", and "Lien Status" is reported as "NA" (code 4)

See p. 9 of GIR on Transactions not to be reported. "Purchase of and interest in a pool of mortgages, such as a mortgage participation certificate, a real estate mortgage investment conduit (REMIC), or a mortgage-backed security".

Are you sure you should even report these?

Good point. If the pool of loans is securitized, you would NOT report it. If, however, the pool of loans was purchased as individual loans, you would report those.

These are whole loans, not securities of any type. We take possession of the note and credit files and assignments. We have reported these in years past.
Thanks to all!